Privacy Policy

Privacy Policy


ALTUS CAPITAL PARTNERS PRIVACY POLICY Updated: June 2018

Altus Capital Partners (hereinafter referred to as either "Altus" or "we", "us" or "our") is committed to maintaining the accuracy, confidentiality, and security of the personal information that we collect in the operation of our websites and services. Your privacy is important to us. To better protect your privacy, we provide this Privacy Policy explaining the types of personal information we collect through our website located at www.altuscapitalpartners.com and the Investor Portal located at https://portal.altuscapitalpartners.com (collectively, the “Site”), how we use the information, with whom we share the information, and the choices you can make about the way your information is collected and used. This Privacy Policy applies only to our privacy practices with respect to the Site and does not apply to any offline practices. In addition, please review our Terms of Use Agreement which governs your use of the Site.

CONSENT

By affirmatively accepting these terms, or otherwise using the Site, you hereby agree with and consent to the collection and processing of your personal information as described in this Privacy Policy.

As further described herein, your personal information may be collected, processed and stored by Altus or its service providers in the United States and other countries where such servers reside. You hereby agree with and consent to the transfer of your personal information to the United States and other countries where we and our service providers operate.

You may have a legal right to withdraw your consent to Altus’s collection and processing of certain personal information, or to the transfer of your personal information across borders. To request to withdraw your consent, please contact us as set forth below.

THE INFORMATION WE COLLECT AT THIS SITE

We collect the following nonpublic personal information (“Personal Data”) directly from you through this Site: 

  • The password and account designation that you enter to access the Investor Access section of the Site;
  • Your name, address, phone number and e-mail address in connection with registering for an account and password;
  • The information that you provide (or revise) in the Prospective Investor / Limited Partner General Information section of the Site, including: financial information (such as banking information and account number); taxpayer ID number; jurisdiction of tax residence; date of birth; and certain investment-related information; and
  • The information that you provide to us in the Feedback section of the Site.

Personal Data may include certain non-public personally identifiable information ("PII"), including but not limited to, your name, address, telephone number, e-mail address, and ID numbers. In all such cases, you choose whether to provide us with such PII, but certain portions of the Site may not be available to you if you do not provide the PII requested. In addition, we may collect certain Personal Data when you visit many of our web pages on the Site through automated means, such as the type of browser you are using, the type of operating system you are using, IP address, your Internet service provider, network location, device characteristics, referring URLs, information on actions taken on our Site, and dates and times of Site visits. One manner of collecting such Personal Data is through cookies. We use “cookies” or similar such devices in connection with our Site and services. Cookies are small bits of data cached or stored on your computer based on Internet activity. We use cookies to monitor individual activity in the aggregate to improve the Site. The information we gather through cookies may include your IP address, user language, the operating system, browser type, the presence/absence of "flash" plug-ins, your screen resolution, connection type and information that identifies the cookie. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. While you may configure your browser to reject cookies, if you do so, you may not be able to use the full functionality of the Site.

We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more information on Google’s Privacy Policy go to https://www.google.com/intl/en/policies/privacy/. Users can opt-out of Google Analytics tracking at​ https://tools.google.com/dlpage/gaoptout.

We may combine the Personal Data you submit directly through the Site with other Personal Data we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as publicly available information sources and other third parties.

HOW WE USE THE INFORMATION WE COLLECT AT THIS SITE

We will not share your Personal Data with any non-affiliated third parties, except for: (i) legal compliance purposes, as described below; (ii) purposes as stated in the "Assignability" section below; (iii) if you give us your consent; or (iv) as expressly set forth within this Privacy Policy. We may share Personal Data (as PII and anonymous information) with entities that perform functions on our behalf. These third parties shall have access to your Personal Data, including PII, only to the extent it is necessary to perform their duties and functions, and subject to this Privacy Policy. We may use the password and account designation that you enter to allow you to access your account. We may use your Personal Data and may share such Personal Data with our affiliated entities (i.e., companies related to us by common ownership or control) to:

  • Update your account information;
  • Fulfill your requests for additional information;
  • As necessary to effect, administer, and enforce a transaction requested or authorized by you;
  • Provide products and services requested or authorized by you;
  • Maintain and service your account(s) with us;
  • Conduct any transactions requested or authorized by you;
  • Perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of PII);
  • Operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions);
  • Protect against, identify and prevent fraud and other unlawful activity;
  • Comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms of Use Agreement;
  • Communicate with you; and
  • Respond to your inquiries with respect to the status of your account.

We may use the anonymous information that we collect to improve the design and content of our Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage. We may share certain anonymous information such as demographics and usage statistics with third parties to perform these functions. When this type of information is shared, the other parties do not have access to your PII. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as Personal Data as long as it is combined.

We may use your Personal Data in other ways for which we provide specific notice at the time of collection.

We may disclose Personal Data in response to legal process, for example, in response to a court order or a subpoena, regulation, binding order of a data protection agency, governmental request, or other legal or regulatory process. We also may disclose Personal Data in response to a law enforcement agency's request, or where we believe it is necessary to protect the confidentiality and security of our records pertaining to you, to limit our legal liability or to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use Agreement, or as otherwise required or permitted by law.

When you are no longer our customer, we continue to share your information as described in this Privacy Policy.

COLLECTION OF INFORMATION BY THIRD-PARTY SITES

Our site may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites' respective privacy policies as we have no control over information that is submitted to, or collected by, these third parties. We are not responsible for the policies or practices of third parties. The privacy practices of third party websites linked to our site are not covered by this Privacy Policy. These other sites may send their own cookies or collect personally identifiable information. We cannot control this collection of information. You should contact these entities directly if you have any questions about their use of the information that they collect.

OUR COMMITMENT TO SECURITY

We have put in place physical, electronic, and managerial procedures as required by law and as we deem reasonable designed to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect through the Site. However, we cannot guarantee the security of any information that is disclosed online. Therefore, we make no warranty regarding the security of any information you transmit to us via the Site and you do so at your own risk.

In addition, we take reasonable steps to ensure that we retain your Personal Data for so long as is necessary for the purpose for which it was collected, or as required under any contract or by applicable law.

NO COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION FROM CHILDREN

The Site is not directed at children and we do not knowingly collect any PII from children under thirteen (13) years of age unless the collection complies with the Children's Online Privacy Protection Act ("COPPA"). If you are under thirteen (13) years of age, do not send any information about yourself to us. If we discover that a child under the age of 13 has provided us with PII, we will use commercially reasonable efforts to delete that child's PII from our system.

RESPONSE TO DO NOT TRACK SIGNALS

Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to digital devices that a visitor does not want to have his/her online activity tracked. Because not all web browsers offer DNT options and DNT signals are not yet uniform, we and many other digital service operators do not respond to DNT signals.

CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light Law”, California residents who provide Personal Data in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information on behalf of Altus, please send an email message to investor.relations@altuscapitalpartners.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the “Shine the Light “requirements and only information on covered sharing will be included in our response.

INTERNATIONAL USERS

We are a United States company and we follow the laws of the United States regarding the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories.  While this Privacy Policy applies to Personal Data generally, the local laws, rules and regulations of jurisdictions that are applicable to us (“Local Laws”) may require standards which are stricter than this Privacy Policy and, in such event, we will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. Your Personal Data may be stored and processed in any country where we have facilities or service providers. In these circumstances we will, as required by applicable law, ensure that your privacy rights are protected by organizational, technical, contractual and/or other lawful means.

EU DATA SUBJECTS

In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to Altus’s use or disclosure of your Personal Data will mean that you cannot take advantage of certain Altus products or services.

We may transfer your Personal Data outside the EU to the United States or any country that Altus or its service providers may have operations. Such countries do not have the same data protection laws as the EU. Any transfer of your Personal Data will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your Personal Data. To obtain a copy of the such safeguards please contact us.

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • Fair processing of information and transparency over how we use your use Personal Data
  • Access to your Personal Data and to certain other supplementary information that this Privacy Policy is already designed to address
  • Require us to correct any mistakes in your information which we hold
  • Require the erasure of Personal Data concerning you in certain situations
  • Receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • Object at any time to processing of Personal Data concerning you for direct marketing
  • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • Object in certain other situations to our continued processing of your Personal Data
  • Otherwise restrict our processing of your Personal Data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation (or other relevant guidance).

If you would like to exercise any of those rights, please Email, call, or write to us with the following:

  • Enough information to identify you
  • Proof of your identity and address
  • The information to which your request relates

HOW TO COMPLAIN

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the EU state where you work, normally live, or where any alleged infringement of data protection laws occurred.

YOUR CHOICES REGARDING YOUR INFORMATION

If you are aware of any discrepancies in your personal profile, or would like to update, review, or remove your Personal Data from our systems, please edit your profile or contact us at any time. You can stop the delivery of certain e-mail and newsletters by following the instructions in the e-mail you receive or updating your online personal profile. If you feel that we have violated this Privacy Policy in any manner, please contact us so we may resolve any concerns.

CAN AN INVESTOR OPT-OUT OF ALTUS COLLECTING PERSONAL DATA?

No, in that as an investor, you consented upon execution of the fund(s) subscription and related documentation; however, you may withdraw from the fund(s) as contracted, and therefore withdraw further consent. Users who wish to opt out of using the investor portal, accessed from Altus’s website, for accessing communications from Altus may do so by contacting us. Altus will provide documents to such investor through another method, such as first class postal delivery, as agreed with the investor. Investors who do not wish to review the Altus website do not have to visit or use the site.

Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information concerning any orders or services you request. You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy for this Site or its implementation you may contact us at 203-429-2000. Any questions or concerns regarding the terms of this Privacy Policy should be directed to: investor.relations@altuscapitalpartners.com, or via mail to Altus Capital Partners, Attn: Privacy Policy, 10 Westport Road, Suite C204, Wilton, Connecticut, 06897, U.S.A. We will contact any person lodging a formal complaint and will cooperate with appropriate regulatory authorities to resolve any complaints that cannot be resolved between us and any individual(s). 

UPDATES & EFFECTIVE DATE

From time to time, we may update the Privacy Policy for this Site without prior notice to you. We will post the updated Privacy Policy on the Site and indicate at the top of the Privacy Policy when it was most recently updated. We will not use PII in a manner materially different than as described in the Privacy Policy in effect at the time the information was collected. We encourage you to periodically check back and review this Privacy Policy so that you always will know what information we collect, how we use it, and to whom we disclose it.

ASSIGNABILITY

Altus reserves the right to disclose, share, assign and/or otherwise transfer your Personal Data, including without limitation PII, in connection with a merger, acquisition, consolidation, the sale of substantially all of its assets, or any other corporate transfer, exchange or restructuring, whatever form it may take. We may transfer information, including your Personal Data, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part).